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Research, Grants and Export Control

Cost Sharing on Sponsored Projects - 1M8

Introduction

Regulations require the University to substantiate, through adequate records, cost sharing expenditures for both direct and indirect (facilities and administrative) cost associated with all external grants and contracts. The records must reflect that direct cost sharing expenditures are appropriate, necessary and incurred within the related project period. Records must also provide evidence that the cost sharing expenditures incurred in a particular fiscal year are included in the development of the University's facilities and administrative cost rate for the same fiscal year.

The SIUE Policy on Cost Sharing has been developed to ensure that the University remains in compliance with State and Federal regulations governing cost sharing arrangements.

Definition of Cost Sharing

The Office of Management and Budget's "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" defines cost sharing as "the portion of project costs not paid by federal funds unless otherwise authorized by federal statute." Specific categories of cost sharing are defined as follows.

  1. Mandatory, or required, cost sharing is:
    1. mandated by law or regulation
    2. stated in a program or project announcement.

  2. Voluntary committed cost sharing is:
    1. solicited or suggested in the program or project announcement
    2. specifically pledged in the proposal's budget or award by the institution.

  3. Voluntary uncommitted cost share is:
    1. personnel effort that is over and above that which is committed and budgeted for in a sponsored agreement.

Cost sharing may be in the form of in-kind, cash or both. In-kind may include the following cost elements:

  1. salary and wages
  2. employee benefits
  3. other expenses
  4. indirect costs associated with direct costs listed above
  5. unrecovered indirect costs.

Cost sharing must be:

  1. verifiable from the institution's records
  2. necessary and reasonable for accomplishment of the project objectives
  3. directly identifiable with the project
  4. incurred during the period of performance of the award
  5. financed from non-federal funds
  6. compliant with federal cost principle guidelines.

Cash cost sharing contributions include:

  1. cash contributions from unrestricted accounts and/or third-party sources
  2. matching funds - cash contributions from unrestricted accounts and/or third party sources. (Matching funds typically require a dollar-for-dollar ratio to qualify for funding.)

Policy

University policy requires that (a) the Office of Research and Projects review agency program guidelines and policy requirements to determine whether cost sharing is mandatory and (b) the Associate Provost for Research review and approve all cost sharing commitments.

When cost sharing is required and/or proposed, the program or project budget will specifically identify the source of University funds that will be used to satisfy the cost sharing commitment on the Grant and Contract Routing Form. Grant accounts will not be activated and/or spending will not be permitted on an award until all cost sharing resources are identified. Voluntary cost sharing commitments require additional written justification.

Responsibilities and Authority

The Associate Provost for Research is responsible for reviewing and approving all cost sharing and matching funds commitments from all units.

The Office of Research and Projects in the Graduate School is responsible for preparing reports to sponsors with regard to cost share expenditures.

In instances when program guidelines require a level of mandatory cost sharing and a commitment is made to cost share funds to a project, the Dean(s) or Vice Chancellor of the principal investigator and co-investigator(s) as well as their Department Chair(s) and/or Director(s) must verify the availability of such funds before submitting the proposal for review to the Office of Research and Projects.

When a sponsor does not provide rules or guidelines that require cost sharing but encourages it in writing, the principal investigator shall consult with his/her Dean or Vice Chancellor and the Associate Provost for Research to determine if cost sharing is appropriate and, if so, at what level.

For proposals that require mandatory cost sharing commitments, the principal investigator/project director must seek approval from the Associate Provost for Research sufficiently before the external deadline to allow an adequate review of the options. The Associate Provost for Research shall assist with identification of appropriate University funds. If a proposal is not submitted due to lack of mandatory cost sharing funds, the Associate Provost for Research must notify the Provost before the submission deadline and notify the Graduate Council at their next scheduled meeting.

In order to identify and document cost sharing expenditures from state funds, each school/college or unit will establish prior to expending cost share funds a state (2) ledger cost share account that will clearly be identified as such in the university's financial accounting system and in which cost sharing expenditures for each sponsored program within that school or unit will be recorded. The school/college or unit is responsible for maintaining separate records and supporting documentation of cost sharing expenditures posted in this account for each sponsored program and providing such documentation to Research Projects and Fiscal Management. The school/college or unit is also responsible for maintaining separate records and supporting documentation of all non-state cost sharing expenditures posted in other accounts for each sponsored program and providing such documentation to Research Projects and Fiscal Management.


Approved by Chancellor effective 7/29/14
This policy was issued on September 15, 2014.
Document Reference: 1M8
Origin: GR 13/14-09

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